Case Summary (G.R. No. 211972)
Applicable Law
The decisions referenced rely on the provisions of the 1987 Philippine Constitution and pertinent laws concerning property ownership, trusts, and the requirements for valid property transfers under the Civil Code of the Philippines.
Factual Background
The subject property was acquired by Felisa Tamio in 1959. In 1960, Felisa reportedly sold the property to her daughter Bella, her son-in-law Delfin Guerrero, Sr., and her common-law husband Felimon Buenaventura, Sr. A subsequent Deed of Sale executed on January 23, 1997, transferred ownership to Wilson and Peter Go, but this transaction was contested by Felisa's other heirs, leading to claims of trust and ownership disputes.
Issues Raised in the Case
The case primarily centered on three issues: whether an implied trust was established by Felisa for the benefit of Bella and Delfin; whether the action for reconveyance had prescribed; and if Wilson and Peter could be classified as purchasers in good faith given their knowledge of the property's prior claims.
Court of Appeals' Ruling
The Court of Appeals found that an express trust existed, as the evidence, particularly a letter from Felisa, indicated her intent to merely entrust the property to Bella and her family for securing a loan, not to convey ownership permanently. They ruled that the action for reconveyance had not prescribed, as the Bihis Family had continuously occupied the property, making their action imprescriptible. The CA also concluded that Wilson and Peter were not purchasers in good faith due to their awareness of competing claims.
Supreme Court's Ruling
The Supreme Court affirmed the Court of Appeals' decision. The Court found that the intentions displayed by Felisa through documented communications more accurately reflected a transfer stemming from trust rather than outright sale. Thus, they rejected the characterization of the trust as implied, confirming it to be express based on Felisa’s specified intentions regarding ownership retention and equitable distribution among her heirs.
Legal Principles Regarding Trusts
The Supreme Court articulated the distinction between implied and express trusts, emphasizing the necessity of clear intention from the trustor. An express trust can be established without specific language indicating the existence of a trust as long as the intention is apparent. The letter dated September 21, 1970, was pivotal in affirming Felisa's ongoing ownership interest, despite transfer documentation that indicated otherwise.
Prescription of Actions for Reconveyance
The Court underscored the legal principle that actions for reconveyance based on express trusts are subject to a ten-year prescription period, commencing from the date of repudiation of the trust. The trust was repudiated upon the sale of the property to Wilson and Peter, with the Bihis Family filing for reconveyance shortly thereafter, thus not breaching the statute of limitations.
Good Faith Purchaser Determination
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Case Overview
- The case involves two consolidated petitions for review on certiorari concerning the Decision dated December 19, 2013, and the Resolution dated April 1, 2014, by the Court of Appeals in CA-G.R. CV No. 96697.
- The petitioners are Wilson Go and Peter Go, while the respondents include the Estate of Felisa Tamio de Buenaventura, represented by Resurreccion A. Bihis, Rhea A. Bihis, and Regina A. Bihis, as well as these individuals in their personal capacities.
- The Court of Appeals modified the Regional Trial Court's (RTC) Decision dated June 8, 2009, which initially recognized the rights of the petitioners and ordered them to pay compensatory damages to the respondents.
Background Facts
- On March 17, 1959, Felisa Tamio de Buenaventura purchased a parcel of land in Quezon City, resulting in the issuance of TCT No. 45951/T-233 in her name.
- In 1960, Felisa allegedly sold the property to her daughter Bella Guerrero, her husband Delfin Guerrero, Sr., and Felimon Buenaventura, Sr., for P15,000.00.
- The title was subsequently transferred to TCT No. 49869 in the names of Bella and Felimon, Sr.
- The property was occupied by Resurreccion A. Bihis, another daughter of Felisa, from 1968 until her death in 2007.
- Following Felisa's death in 1994, a disputed will was presented, which bequeathed half of the prop